Health and safety in the spotlight July 01st 2010
The EU promotes a 'better/smart' regulatory system and UK Government has echoed this through its own efforts to simplify legislation. The coalition Government has taken that a step further by encouraging all to put their ideas into what is seen as unnecessary or over bureaucratic legislation and has instigated a review into health and safety. Greg Bordiak, technical officer of BCAS believes we should take a little time to review what we have and decide what to get rid of or reduce its effect.
Since most legislation emanates from Brussels and member states have little manoeuvring capability it goes without saying that the 'better/smart' approach must come from Brussels. As far as compressed air systems and industry are concerned the vast majority of legislation is European-wide regulation. It is only in the field of 'in-use' legislation when member states have their own sovereign rights to do as they see fit. That is no different in the UK which has the Pressure Systems Safety Regulations to control the continued fitness of compressed air systems.
The primary piece of industrial legislation which, surprisingly, is a UK-only regulation is of course the Health and Safety at Work Act which since 1974 has introduced the concept of risk assessment.
This in itself provided for the general principles to be met by all players in the industrial field. Since 1974 it has been strengthened by other secondary legislation which, it could be suggested, is not required!
The Management of Health and Safety at Work Regulations reinforced the need for the risk assessment approach to protect the worker and enhance safety in the work place. The HSE identified the '5 steps' approach so that those using compressed air could identify where their hazards were. From this the hazard from the indiscriminate use of blow guns could be identified.
The Provision and Use of Work Equipment Regulations provides for the equipment to be suitable for its intended use and that those operating it are given training and that the equipment is maintained in a safe condition. It is also a key piece of legislation for second-hand equipment which is widely sold and used in industry. Whereas a compressor manufacturer places a compressor on the market in compliance with the Machines Directive, that only applies when the compressor is first sold. Once in the marketplace it can be subject to the user’s own priorities especially in matters of service and maintenance. It is at least fortunate that the second-hand compressor, or at least the purchaser, is subject to PUWER so that the compressor just purchased with a missing guard shall be made safe before use.
The Control of Noise at Work Regulations seeks to reduce disabling conditions such as tinnitus and deafness from noisy machinery. Action and limits have been placed on the daily exposure of workers to noise. Compressors are now increasingly placed within the working environment no longer are they placed in the luxury of their own room to keep the noise away from the workers.
Compressors are conveniently packaged in their own acoustic box to keep the noise down to below even the limit values for daily exposure. Compressed air operated equipment can still exhaust air into the working environment so the risk of noise needs to be assessed to keep within the daily exposure levels.
The Control of Vibration at Work Regulations seeks to reduce the disabling conditions created by exposure to handarm vibration from powered hand-held tools. Daily action and limit values are imposed to help in this move to seek a reduced risk working environment.
Pneumatic powered hand-held tools have all been the subject of improved design to reduce vibration at source. Those pneumatic tools can only maintain their reduced vibration performance if the operators are trained in their correct use.
The pneumatic tools can only preserve their designed reduced vibration if they are maintained correctly and the consumables are those recommended for the equipment. The regulations call for all of this.
The Pressure Systems Safety
Regulations replaced a previous Factory Act that had a very limited scope and which only focussed on a single item of equipment, the air receiver, for special treatment. The new regulations, fully in place since 1994, widened its scope to the complete compressed air system and removed specific inspection periods with risk assessed time periods. This was in recognition that all compressed air systems were different. The regulations deal with design, installation, inspection and maintenance as well as many other aspects which contribute to the safe operation of a compressed air system.
So what shall we vote to give up in this supposed regulatory excess of legislation?
Yes, let us leave risk assessment out of it and rely on common sense. Who needs to be familiarised with the correct shut down procedure for that bank of compressors when there is a switch on the wall; even though other equipment may rely on the compressed air for safety reasons.
Noise, what noise? Having gone deaf, you don’t need to wear those ear defenders and while you are about it that new grinder would work better if it was fitted with a wire brush rather than a sanding disc. The vibration from the grinder is much higher but then the job may get done before your finger tips go white! Who needs training it only slows the job down!
The compressed air system has been okay for years and the air receiver did have a pressure test once and the garden hose is only a 'temporary' measure! Maintenance that is a good idea we will have some done soon but inspection sounds expensive and anyway no one has asked to look at the system.
Remaining competitive is essential but not at the cost of killing and maiming the workforce. It is no longer acceptable to believe that your working life will result in you becoming as 'mad as a hatter' or suffer silicosis or not be able to order three pints because there was no guard on that guillotine only a message saying 'keep clear'. You went to work to earn a living not to become disabled and you certainly expected to go home after work rather than be carried out in a box after that boiler or air receiver exploded!
On the whole regulation is beneficial; where it falls down is when it is overzealously applied when that phrase in all UK legislation is forgotten ‘so far as is practicable’.
For further information and impartial advice regarding compressed air systems, please contact the British Compressed Air Society on 0207 935 2464 or visit www.bcas.org.uk More articles from British Compressed Air Society (BCAS): |